EAA hardware and self-service terminals

In brief

The European Accessibility Act covers certain consumer products: general purpose computer hardware and operating systems, self-service terminals, consumer terminal equipment for communications and audiovisual media, and e-readers (Article 2(1)). They must meet Annex I, Section I. Section II adds packaging and instructions for all of them except self-service terminals.

Products must comply when placed on the market after 28 June 2025. Article 32 allows existing self-service terminals to stay in use for a limited time.

Which products?

See EAA scope for the full list in Article 2(1).

Section I: all products

Products must be designed and produced to maximise foreseeable use by persons with disabilities. Section I covers information provision, user interface and functionality design, and support services. The user interface and functionality requirements include, in our reading:

• communication through more than one sensory channel, with alternatives to vision, hearing, speech and touch;
• alternatives to speech and voice input;
• ways to magnify and to adjust brightness and contrast;
• alternatives to colour and to audible signals;
• controls for volume, speed and audio clarity;
• avoiding operation that needs extensive reach or strength;
• avoiding triggers for photosensitive seizures;
• privacy when accessibility features are used;
• a non-biometric alternative;
• consistent functionality and adjustable time limits.

Check the exact wording of Annex I before you cite it.

Self-service terminals

Section I, point 2(o)(i) adds seven requirements for self-service terminals:

1. support text-to-speech;
2. let users connect their own personal headsets;
3. where a timed response is needed, alert the user through more than one sense;
4. offer a way to extend the allotted time;
5. provide good contrast and, where keys or controls exist, make them distinguishable by touch;
6. do not require a user who needs an accessibility feature to activate it first;
7. where audio or audible signals are used, work with assistive devices common across the Union, such as hearing aids, telecoils, cochlear implants and assistive listening devices.

Section II: packaging and instructions

For products other than self-service terminals, Section II asks for accessible packaging and accessible information on it, and publicly available instructions for installation, maintenance, storage and disposal. The instructions must be offered in more than one sensory channel, be understandable and perceivable, use adequate font sizes and contrast, use text formats that can be converted to alternative formats, and give alternatives for non-text content.

Existing terminals

Under Article 32(2), Member States may allow self-service terminals lawfully used to provide services before 28 June 2025 to remain in use until the end of their economically useful life, but no longer than 20 years after they entered use.

Software on the device

A terminal or app screen is also covered by the digital requirements of your service. See the checklist pages, starting with keyboard access and name, role, value.

What to do

• List products in scope. Check each against Article 2(1).
• Check Section I. Information, interface, functionality and support.
• Check the seven terminal requirements. Text-to-speech, headset, alerts, time, contrast, tactile controls, no pre-activation, hearing devices.
• Review packaging and instructions. Section II applies to all products except terminals.
• Document the lifecycle. Record which terminals rely on Article 32(2).

Common mistakes

• Touchscreen-only terminals. Keys or controls must be distinguishable by touch where they exist, and text-to-speech is required.
• Accessibility settings behind a menu. Users who need a feature should not have to switch it on first.
• Fixed time limits. Terminals must warn through more than one sense and offer more time.
• PDF-only manuals. Instructions must be in accessible formats.
• Assuming old terminals are exempt for ever. Article 32(2) is limited to the economically useful life and 20 years from entry into use.

Sources

• Directive (EU) 2019/882, European Accessibility Act (EUR-Lex), opens in a new tab

This page is for informational purposes only and is not legal advice. For binding requirements, refer to the official text of the European Accessibility Act (Directive (EU) 2019/882) and to the national law of the Member State where you operate.